From: Richard Joslin C

From: Richard Joslin C To: jeffrey E. <[email protected]>, "Dlugash, Alan" CC: Brad Wechsler a, John Castrucci ca Subject: updated draft Date: Thu, 08 Oct 2015 18:25:19 +0000 Attachments: FEDERAL_-_DRAFT -_10-7-15_-_626PM_to_JEE.pdf Minor revisions. The largest change was to treat a PFIC mark to market ordinary income to NOT be an excess distribution. Tom had confused the tax rules. This item originates from a foreign partnership and is not reported on the foreign partnership Schedule K-1. The foreign partnership prepares a pro forma K-1 and does not actually file it with the IRS. Same password as before EFTA00650696